What is the standard of care required by the occupier of a parking lot to properly prepare the lot for icy winter conditions?

Manitoba, Canada


The following excerpt is from Robertson v. 6177655 Manitoba Inc. et al., 2020 MBQB 24 (CanLII):

With respect to icy winter conditions, Stortini J. made the following comments in the decision of Baker v. Rupert Acres [1997] O. J. No. 363 (O. C. J. Gen. Div.) beginning at para. 5: ‘It has been held that it is necessary for the occupier to inspect and to protect lawful users if the conditions become dangerous by blocking access to dangerous areas in the lot, by sanding or salting, or by any other reasonable and inexpensive means. … The standard of care may be met if there is unusual weather conditions, and if the occupier had procedures in place for the clearing, salting sanding and inspection of its premises.’

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